Tax Policy

A global view on tax policy

With tax policy developments around the world quickly evolving, multinational organizations need to take a global view of the implications for their businesses, while also keeping an eye on specific jurisdictional considerations that may have an impact.

��㣨Leyu��’s Tax Policy Leadership Group includes leading thinkers from around the world who convene weekly to discuss the latest issues in tax policy. The group engages with countries and jurisdictions across the organization and in the external market, and regularly publishes perspectives on new developments and the potential impacts and key considerations for multinational organizations.

Explore this page to view ��㣨Leyu��professionals�� responses to the latest OECD developments, as well as insights into the latest tax policy developments taking place around the world.

Latest updates:

April 2025

Top 10 areas to watch for in 2025

A few months into 2025, many Multinational Enterprises have their Pillar Two preparations well underway, while others are still engaged with preliminary efforts. 2025 is set to be a year in which Pillar Two becomes ever more ‘real��. The second ‘wave�� of jurisdictions will put their Pillar Two rules into effect. This article explores the top 10 areas to watch for in 2025 for Pillar Two.

15 January 2025

On January 15, 2025, the Inclusive Framework (IF) on BEPS released a fifth tranche of Administrative Guidance (AG5) on a specific provision dealing with the use of deferred tax assets under the GloBE transitional rules. Other material concerning the GloBE Information Return, the qualification process and exchange of information were also released. This brief focuses on the guidance on deferred tax assets under Article 9.1.

On January 15, 2025, the Inclusive Framework on BEPS (“IF��) released a series of documents (running to approximately 330 pages) on the application of the Global Anti-Base Erosion (“GloBE��) Rules. The primary focus is compliance and reporting obligations, though there was also some limited additional Administrative Guidance (“AG��) that amends certain aspects of the Commentary to the GloBE Model Rules.

17 June 2024

On 17 June 2024, the OECD released the fourth tranche of Administrative Guidance. This covers deferred tax liability recaptures, divergences between GloBE ad accounting carrying values, allocation of Cross-border Current Taxes, Allocation of Cross-border Deferred Taxes, Allocation of profits and taxes in structures including Flow-through Entities and Treatment of Securitisation Vehicles.��

The OECD’s fourth tranche of Administrative Guidance on the Global Anti-Base Erosion (“GloBE��) Model Rules (“June 24 AG��).

The OECD’s additional guidance on key definitions related to Amount B.

View ��㣨Leyu�� professionals�� responses to the latest tax policy developments

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Summarizing the 19 February 2024 OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting release on Amount B.
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Summarizing the 18 December 2023 Inclusive Framework release of Administrative Guidance on the GloBE Rules.

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Summarizing the latest OECD releases on Amount A of Pillar 1 from 11 October 2023

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Review of the recent OECD/G20 BEPS Inclusive Framework release.��

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Review of the recent Secretary General of the United Nations release from August 2023.��

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An overview of Pillar Two implementation developments in jurisdictions around the world.
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��㣨Leyu�� response to the tax-treaty based role that allows for the levying of additional tax.
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��㣨Leyu�� response to the second set of Administrative Guidance on GloBE rules.
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Grant Wardell-Johnson, Global Tax Policy Leader, ��㣨Leyu�� International and Michael Lennard, Chief of the International Tax Corporation Unit of the Financing for Sustainable Development Office, United Nations, discuss the most important developments in international tax rules.